16.523 JUVENILE ACCOUNTABILITY BLOCK GRANTS APRIL 2012 State Project/Program: Federal Authorization: Public Law 107-273 State Authorization: JUVENILE ACCOUNTABILITY BLOCK GRANTS (JABG) U. S. Department of Justice N. C. Department of Crime Public Safety Governor s Crime Commission Agency Contact Person Program Kimberly Williams, Lead Juvenile Justice Planner (919) 733-4564 Agency Contact Person Financial Elaine Freeman (919) 716-3013 Address Confirmation Letters To Fiscal Arie Davis, Director of Grants Management N.C. Dept. of Crime Control and Public Safety Governor s Crime Commission 1201 Front Street, Suite 200 Raleigh, NC 27609 (919) 733-4564 The auditor should not consider the Supplement to be safe harbor for identifying audit procedures to apply in a particular engagement, but the auditor should be prepared to justify departures from the suggested procedures. The auditor can consider the supplement a safe harbor for identification of compliance requirements to be tested if the auditor performs reasonable procedures to ensure that the requirements in the Supplement are current. The grantor agency may elect to review audit working papers to determine that audit tests are adequate. I. PROGRAM OBJECTIVE The purpose of the JABG Program is to provide States and units of local government with funds to develop programs to promote greater accountability in the juvenile justice system. II. PROGRAM PROCEDURES The awarding Federal agency (DOJ) announces its programs available for funding in the Federal Register. The State submits its Application for Federal Assistance (SF 424) and DOJ reviews the application and approves it with an Award Document (Form 4000/2) which provides the grant period, the award amount, special conditions, etc. The State accepts the award by signing the Award Document and returning it within 45-days from the beginning date of the award. The State then announces its programs available for funding every year by November in its Announcement of Availability of Federal Grant Funds. All eligible applicants are listed in the Announcement. Eligible applicants are local units of government, councils of government, universities or colleges, independent school systems, state agencies and the Eastern Band of Cherokee Indians. Eligible applicants (Implementing Agencies) then submit a pre-application for a project for review by the Governor s Crime Commission. Grant applications are available from the Governor s Crime Commission web site at www.ncgccd.org. Once the pre-applications are reviewed and ranked, selected recipients are then notified by April 1 st that they are then required to submit a full application with additional information for review. Once a grant project is finally selected for funding, a Grant Award is issued which provides the federal award amount, the grant period, special conditions, etc. The grantee accepts the award by signing the Award document and returning it within 30-days from date the award is mailed. The grant project must be operational within 60-days of the beginning of the grant and so certified by a Notice of Grant Implementation Report. B-4 16.523 1
The Office of Justice Programs Financial Guide and the GCC Grant Award Packet must be used for the administration of this grant. III. COMPLIANCE REQUIREMENTS AND SUGGESTED AUDIT PROCEDURES A. ACTIVITIES ALLOWED OR UNALLOWED The U.S. Department of Justice, Office of Juvenile Justice & Delinquency Prevention has designated program purpose areas, as enumerated in H.R. 3. The Governor s Crime Commission then selects their funding priorities from those 16 JABG program areas and those are listed in our Announcement. Federal grant funds can then only be expended on those services that are directly related to their approved grant application. Their project is directly related to one of the federally recognized program areas. The specific project activities allowed are those found in the Project Narrative (Operation) section, Timeline of Project Activities, and Project Goals, Objectives, Performance Measures, and Evaluation Methods section of the full application. 1. Review the full grant application and note the following sections; Project Narrative (Operation), Timeline of Project Activities, and Project Goals, Objectives, Performance Measures, and Evaluation Methods. 2. Test expenditures and related records for adherence to the approved grant budget and subsequent grant budget adjustments. B. ALLOWABLE COSTS/COST PRINCIPLES All grantees are required to abide by the Office of Management and Budget (OMB) Circulars and Code of Federal Regulations, as applicable: A-102, 2 CFR Part 210 - Uniform Administrative Requirements for Grants and Agreements with State and Local Governments; 2 CFR Part 215 - Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations; 2 CFR Part 220 - Cost Principles for Educational Institutions; 2 CFR Part 225 - Cost Principles for State, Local, and Indian Tribal Governments; and, 2 CFR Part 230, Cost Principles for Non-Profit Organizations. The grantee must also comply with the Standard Grant Conditions as stated in the Grant Award Packet, which is distributed by the Governor s Crime Commission. The Governor s Crime Commission, as a part of their monitoring efforts, considers allowable costs to be those that are listed in the approved grant application budget section of the approved full application and those which would be included on any approved grant budget adjustments. B-4 16.523 2
1. Review full grant application budget. 2. Test expenditures and related records for adherence to approved application budget and any subsequent approved grant budget adjustments. C. CASH MANAGEMENT Funds are submitted to all grantees from DCCPS-GCC on a reimbursement basis. No testing is required since funds are not advanced to grantees. F. EQUIPMENT AND REAL PROPERTY MANAGEMENT Grantees are instructed to follow their own written policies for equipment purchases. If they do not have a written policy, they should follow the procedures in the Grant Award Packet that is distributed to all grantees each year. All equipment purchases should be for the purposes or activities of the grant only. The title for equipment purchased under the grant is vested with the implementing agency. The procedure for disposal of equipment is outlined in the Grant Award Packet. According to the Grant Award Packet which is distributed to each grantee, the grantee is required to keep a Property Control Record Form for all equipment purchased with grant funds. The Governor s Crime Commission considers equipment as any item with a value of $500.00. 1. Verify that the grantee is, in fact, properly keeping the Property Control Record Form. 2. Verify if the equipment still exists and is being used as stated in the full application. 3. Verify as to whether or not the equipment has been disposed of and if the grantee has requested and properly followed disposition instructions from the awarding agency. G. MATCHING, LEVEL OF EFFORT, EARMARKING The grantee must finance the match indicated in the budget of the Award Document and on the front page of the full grant application with their own funds. They must describe their source and amount of match in the budget summary of the full application under the section entitled, Description of Match. The match ratio for these federal funds is 75% federal funds 25% matching funds. Matching funds may include local, state or private funds, but not other federal funds. B-4 16.523 3
Level of Effort and Earmarking are not applicable at the local level and no test work is required. 1. Review Award Document for total federal funding. 2. Test expenditures and reports to ascertain total cost of project and verify non-federal matching requirements met. 3. Verify source of non-federal matching funds. 4. Verify that the funds awarded will not be utilized to supplant State and/or local funds that would otherwise be available to the grantee or supplant other federal funds with JABG funds. H. PERIOD OF AVAILABILITY OF FEDERAL FUNDS Federal funds can only be obligated within the period of availability listed on the Grant Award document or as amended on a Grant Adjustment form. Obligations must be liquidated within the required time period. The grantee has 45-days within which to request their final reimbursement of funds. Failure to request funds within this time frame could result in the grantee not being reimbursed their final reimbursement of funds. 1. Test a sample of transactions charged to the Federal award after the end of the period of availability and verify that the underlying obligations occurred within the period of availability and that the liquidation (payment) was made within the allowed time period. 2. Test a sample of transactions that were recorded during the period of availability and verify that the underlying obligations occurred within the period of availability. I. PROCUREMENT, SUSPENSION AND DEBARMENT According to the aforementioned OMB Circulars and Code of Federal Regulations (A-102, 2CFR Parts 215, 220, 225 and 230) and as stated in the Grant Award Packet, the grantee must comply with Federal Debarment and Suspension regulations by requiring completion of the Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions by sub-recipients prior to entering into a financial agreement with the sub-recipients for any transaction as outlined below: Any procurement contract for goods and services, regardless of amount, under which the sub-recipient will have a critical influence on or substantive control over the transaction. The grantee is responsible for monitoring the submission and maintaining the official document for review by the Governor s Crime Commission. B-4 16.523 4
1. As stated in the Grant Award Package, verify that all contracts have received prior approval by the Governor s Crime Commission prior to execution. 2. A certification regarding suspension and debarment is required from the contractor. J. PROGRAM INCOME According to the Grant Award Packet that is distributed to all grantees, all program income generated by this grant during the project period must be reported to the Governor s Crime Commission and must be put back into the project or be used to reduce the grantor participation in the program. The use or planned use of all program income must have prior written approval. 1. Test to verify that program income was properly tracked and accounted for. 2. Ensure that program income was used to make additional services available for juvenile justice. 3. Verify that the grantee did in fact receive prior written approval for the use or planned use of their program income. L. REPORTING The grantee is required to submit to the Governor s Crime Commission Grants Management Section the Notice of Grant Implementation form within sixty days of the beginning of the grant period, normally July 1 st during the regular grant cycle. The grantee is required to submit monthly Expense Reimbursement Report for reimbursement by the Governor s Crime Commission. The Expense Reimbursement Report is a one page document, which the grantee uses to report their monthly expenditures according to the five major budget categories (personnel, contractual, travel, supplies/operating expenses, and equipment). Along with the Expense Reimbursement Report, the grantee is requested to send photocopies of all expenditure documentation (i.e. time sheets, travel logs, purchase orders, etc.). The grantee is also required to submit Juvenile Justice (JJ) reports three times each year. A mid-year report is due six months after the grant begins and a final report is due at the end of each project year. An annual performance report must also be completed. Performance Report due dates are dictated by the funding source. Payment of the final expense reimbursement report will not be made without the submission of the final programmatic report. Instructions for reports and reporting are included in the Grant Award Package. B-4 16.523 5
1. Review the grantee s procedures for preparing the State Reports and evaluate for adequacy. 2. Test reports for completeness. 3. Trace data on reports and verify that they agree with supporting documentation. 4. Review adjustments made to General Ledger amounts in the reports affecting State and/or Federal programs and then evaluate for propriety. M. SUBRECIPIENT MONITORING The grantee does not sub-grant funds to sub-recipients. No testing is required at the local level for sub-recipient monitoring. B-4 16.523 6